Corrective Action Plans

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FINDING 2025-007 – COD Disbursement Dates Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The Common Origination and Disbursement System (“COD”)...
FINDING 2025-007 – COD Disbursement Dates Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The Common Origination and Disbursement System (“COD”) disbursement date did not agree with the disbursement date on the students’ accounts for one of the seventeen students in our compliance testing sample. Corrective Action Plan: The Student Financial Aid Director correct the date the aid was posted to the student account in December 2025. Procedures will be improved to ensure that the disbursements date per COD and the student account agree. Anticipated Completion Date: The corrective action was completed in December 2025. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000
FINDING 2025-006 – Federal Direct Loan Eligibility Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $484, net Condition Found: The amount of subsidized Feder...
FINDING 2025-006 – Federal Direct Loan Eligibility Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $484, net Condition Found: The amount of subsidized Federal Direct Loans awarded was incorrect for four of the ten students in our sample that received Federal Direct Loans. In addition, the two of the students was eligible for additional Federal Direct Loan funds. Corrective Action Plan: For the first student, the student was eligible to receive $5,500 of subsidized funds, but only $4,500 was requested. The University gave the student an additional $1,000 of institutional funds to cover the difference in the amount the student was eligible to receive and the amount requested from the Department of Education in December 2025. For the second student, the COD correctly shows the that $5,500 of subsidized aid was disbursed to the student. However, only $4,500 of subsidized loan funds were posted to the student’s account. An institutional scholarship of $1,000 was posted to the student account in December 2025. For the third student, $484 of subsidized loan funds were returned to the Department of Education in December 2025. For the fourth student, the Director of Financial Aid will work with third party administrator to reclassify the subsidized loan funds as unsubsidized loan funds. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000
FINDING 2025-005– NSLDS Reporting Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: During our compliance testing, student enrollment sta...
FINDING 2025-005– NSLDS Reporting Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: During our compliance testing, student enrollment status changes were reported to the National Student Loan Database System (“NSLDS”) timely for nine of the seventeen students selected for testing. Corrective Action Plan: A new Student Financial Aid Director was hired in July 2025. The Student Financial Aid Director and Registrar will work together to determine and report student enrollment status changes within the required timeframe to NSLDS. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000
FINDING 2025-004– Reporting/Internal Control Over the SEFA Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($509,088) 84.007 ($ 5,400) Award Number: P268K253315 P063...
FINDING 2025-004– Reporting/Internal Control Over the SEFA Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($509,088) 84.007 ($ 5,400) Award Number: P268K253315 P063P243115 P007A243421 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: Undetermined Condition Found: The University lacked policies and procedures to reconcile the SEFA data to the financial statements or other supporting documentation. The University was on the HCM2 method of payment and could not provide of the listing by student of the aid requested. During the audit, we were unable to reconcile the Amount Due from the Government on the Financial Statement to the amount due per the financial aid records. In addition, aid was posted to student accounts and never requested from the government for five of the seventeen students in our sample. Corrective Action Plan: The bursar, business office staff, and financial aid staff will work together to review and reconcile Title IV posted to the student accounts to the amounts requested from the Department of Education. When discrepancies are found, the University staff will investigate and determine if the student was eligible for aid and request additional funds as necessary. See the possible effect section for the resolution of the students in this finding. Anticipated Completion Date: The University anticipates the corrective action being completed by June 30, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000
84.063 ($509,088) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University was placed on the Heightened Cash Monitoring Method 2 (“HCM2”) for disbursing aid in May 2023. In the current fiscal year, a Title IV Credit...
84.063 ($509,088) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University was placed on the Heightened Cash Monitoring Method 2 (“HCM2”) for disbursing aid in May 2023. In the current fiscal year, a Title IV Credit Balance was held for more than 14 days for one of the seventeen students in our sample. Corrective Action Plan: There is no longer a credit balance on the account of the student in question. If time allows, the business office will review student accounts to determine if any additional credit balances should be refunded. Procedures should be improved to ensure the University is following the HCM2 regulations. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000
FINDING 2025-002 – Exit Interview Program Name: Federal Direct Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: Six of the seventeen federal student financial aid recipients...
FINDING 2025-002 – Exit Interview Program Name: Federal Direct Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: Six of the seventeen federal student financial aid recipients in our sample did not complete or were not sent exit interview instructions to complete within thirty days of the student ceasing to be enrolled in the University at least half-time. Corrective Action Plan: A new Financial Aid Director was hired in July 2025. The Financial Aid Director will review the students in question to determine if exit instructions were sent after the thirty-day time period. If an exit interview has not already been sent, the Financial Aid will mail exit interview instructions to the students’ home address. In addition, the Director of Financial Aid will work with the third-party administrator to determine which entity is responsible for sending exit interview information to students. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000
FINDING 2025-001 – Financial Close and Reporting Condition Found: During our audit, we noted the following: • Adjustments were necessary for accounts receivable, bad debt, scholarships, deferred revenue and depreciation, and for assets held for sale. Corrective Action Plan: The University will put p...
FINDING 2025-001 – Financial Close and Reporting Condition Found: During our audit, we noted the following: • Adjustments were necessary for accounts receivable, bad debt, scholarships, deferred revenue and depreciation, and for assets held for sale. Corrective Action Plan: The University will put processes in place to adjust accounts to the actual balance before the audit begins. Anticipated Completion Date: The corrective action will be completed by June 30, 2026. Contact Person: Tim Van Horn, Chief Financial Officer 405-200-5311
The City of Herrin is aware of the need to produce a schedule of expenditures of federal awards. Management is going to incorporate proper training and education on the information and amount that must be outlined in the schedule of expenditures of federal awards. The City of Herrin will prepare a s...
The City of Herrin is aware of the need to produce a schedule of expenditures of federal awards. Management is going to incorporate proper training and education on the information and amount that must be outlined in the schedule of expenditures of federal awards. The City of Herrin will prepare a schedule of expenditures of federal awards annually as part of the year­end closing process each year and provide the schedule and all backup used to prepare it to the audit firm during the financial audit process. These Corrective Steps were complete and implemented by December 15, 2025.
Corrective actions were implemented for the Fall 2025 term to ensure all students are notified of Direct Loan disbursements and that sufficient documentation is maintained.
Corrective actions were implemented for the Fall 2025 term to ensure all students are notified of Direct Loan disbursements and that sufficient documentation is maintained.
Action Taken enCircle noted during the audit that federal expenditures were being billed into multiple revenue accounts depending on the nature of the expenditure (internal expense, client reimbursable expense, foster parent payments). These accounts have all been consolidated into one account to en...
Action Taken enCircle noted during the audit that federal expenditures were being billed into multiple revenue accounts depending on the nature of the expenditure (internal expense, client reimbursable expense, foster parent payments). These accounts have all been consolidated into one account to ensure internal and external reporting does not exclude billed expenditures.
Action Taken enCircle believes the measures taken for 2025-001 and 2025-002 are sufficient to address this finding. Further the measures taken for 2025-003 alleviate control and reporting issues related to the Schedule of Expenditures of Federal Awards. Finally, enCircle on top of already occurring ...
Action Taken enCircle believes the measures taken for 2025-001 and 2025-002 are sufficient to address this finding. Further the measures taken for 2025-003 alleviate control and reporting issues related to the Schedule of Expenditures of Federal Awards. Finally, enCircle on top of already occurring monthly program financial reviews is adding a monthly budget review for each federal grant with the programmatic staff.
Action Taken enCircle has officially adopted the policy that gift cards provided to foster parents will not be submitted for reimbursement until the receipts are returned by the parents. If they do not spend the entire amount, only the amount spent will be requested for reimbursement and enCircle wi...
Action Taken enCircle has officially adopted the policy that gift cards provided to foster parents will not be submitted for reimbursement until the receipts are returned by the parents. If they do not spend the entire amount, only the amount spent will be requested for reimbursement and enCircle will cover the difference from non-federal funds. enCircle is also considering other methods of helping parents purchase clothes for foster placements. Further, enCircle has evaluated the use of all allocation methods for expenses that impact federal grants and will be limiting allocations to only clearly explicit expenses to ensure only programmatic costs are billed. Further, enCircle has created a new service code within its Chart of Accounts to track programmatic administration costs separate from overall administration costs.
Action Taken enCircle has developed a new budget tracking tool at the correct budget line items to ensure all categories do not go over budget before budget amendments are submitted and approved. Included in this tool is predictive analytics to determine where budget amendments might be needed proac...
Action Taken enCircle has developed a new budget tracking tool at the correct budget line items to ensure all categories do not go over budget before budget amendments are submitted and approved. Included in this tool is predictive analytics to determine where budget amendments might be needed proactively instead of reactively.
Atwood Elder Housing, Inc. respectfully submits the following corrective action plan for the year ended October 31, 2025: Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street Suite 1200 Braintree MA 02184 Audit period: November 1, 2024 - October 31, 2025 The finding fr...
Atwood Elder Housing, Inc. respectfully submits the following corrective action plan for the year ended October 31, 2025: Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street Suite 1200 Braintree MA 02184 Audit period: November 1, 2024 - October 31, 2025 The finding from the October 31, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings - Federal Award Findings and Questioned Costs Finding 2025-001 - Eligibility - Significant Deficiency Recommendation: Management should review its internal controls over performing tenant recertification procedures to ensure compliance with eligibility requirements. Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility is done in accordance with guidelines specified by federal regulations. Action Taken: Management agrees with the assessment and resulting finding. Corrective actions have been implemented to strengthen compliance controls, including calendar reminders for compliance team members, enhanced documentation in recertification checklists to clarify specific program requirements, and routine review of compliance expectations during monthly staff training and meetings. Management has also increased supervisory oversight and implemented periodic internal file audits to monitor adherence to recertification procedures and prevent future occurrences.
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College re-evaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explan...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College re-evaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Early in the 2024-25 fiscal year, the College learned that this finding related to manually reported graduates and withdrawn students. Graduates reported during the automated file submittal process were reported as graduating at end of term, while graduates reported manually were reported as graduating on the College’s actual commencement date (one day different than end of term). The Registrar is now consistent in reporting graduation dates using the end of term for all graduating students. As for the reporting of withdrawals, the Registrar now manually updates the enrollment status and effective dates in NSLDS to ensure accurate and timely reporting. The findings in this audit period occurred prior to the above changes being implemented. Name(s) of the contact person(s) responsible for corrective action: Austin Nyhof, Registrar Planned completion date for corrective action plan: June 30, 2026
Action taken in response to finding: The Department of Education implementation delays contributed to the untimely reporting. In the event the Department of Education implements future changes, the University will evaluate impacted processes at that time to determine appropriate action. In addition,...
Action taken in response to finding: The Department of Education implementation delays contributed to the untimely reporting. In the event the Department of Education implements future changes, the University will evaluate impacted processes at that time to determine appropriate action. In addition, the Office of Student Finance has evaluated potential process improvements and is actively working with IT support to help automate this financial aid verification process. The University has also increased the frequency of queries within the student records system to identify and update/resolve the records in a timelier manner. Name(s) of the contact person(s) responsible for corrective action: Nate Peterson, Executive Director, Office of Student Finance Planned completion date for corrective action plan: February 2026 If the Department of Education has questions regarding this plan, please call Nate Peterson at 612-624-9442.
Finding #2025-002 (Late Submission to the Federal Audit Clearinghouse) Responsible Party: Sara Hudson & JCCS PC Anticipated Completion Date: Septemer 1, 2025 (Implemented) Corrective Action Planned: Snowy Mountain Development Corporation has engaged a new audit firm and strengthened management overs...
Finding #2025-002 (Late Submission to the Federal Audit Clearinghouse) Responsible Party: Sara Hudson & JCCS PC Anticipated Completion Date: Septemer 1, 2025 (Implemented) Corrective Action Planned: Snowy Mountain Development Corporation has engaged a new audit firm and strengthened management oversight of the audit process and related submission deadlines. Management now actively monitors audit progress, coordinates required deliverables, and tracks federal filing deadlines to ensure timely submission to the Federal Audit Clearinghouse. These procedures have been implemented for the fiscal year ending June 30, 2026. Management anticipates that future Single Audit reports will be completed and submitted in compliance with applicable federal requirements.
FINDING #2025-001 (SF-425 Financial report – Late Submission) Responsible Party: Sara Hudson & Tonya Garber Anticipated Completion Date: November 1, 2025 (Implemented) Corrective Action Planned: Snowy Mountain Development Corporation has implemented updated procedures to ensure timely preparation, r...
FINDING #2025-001 (SF-425 Financial report – Late Submission) Responsible Party: Sara Hudson & Tonya Garber Anticipated Completion Date: November 1, 2025 (Implemented) Corrective Action Planned: Snowy Mountain Development Corporation has implemented updated procedures to ensure timely preparation, review, and submission of SF-425 Federal Financial Reports. Management reviewed current HRSA reporting requirements and established internal reporting deadlines that precede federal due dates. Reporting responsibilities and deadlines have been formally communicated to applicable staff, and management now monitors compliance with submission timelines to ensure reports are filed in accordance with federal requirements. This corrective action has been implemented for the current fiscal year ending June 30, 2026, and management anticipates compliance with SF-425 reporting requirements for future audits.
Compliance Requirement: Other – Inaccurate reporting of the Schedule of Expenditures of Federal Awards Campus: Sacramento, Sonoma Recommendation: KPMG recommends the University implement a system of internal control that is designed and operating effectively to ensure the SEFA is complete and accura...
Compliance Requirement: Other – Inaccurate reporting of the Schedule of Expenditures of Federal Awards Campus: Sacramento, Sonoma Recommendation: KPMG recommends the University implement a system of internal control that is designed and operating effectively to ensure the SEFA is complete and accurate. Corrective Action Plan: California State University, Sacramento The University concurs with the recommendation. The University will review and enhance its procedures and internal controls to ensure the SEFA is complete and accurate. Estimated Completion Date: July 2026 Contact person: California State University, Sacramento Tabitha Leeds Senior Director of Accounting Services (916) 278-4679 leeds@csus.edu Corrective Action Plan: Sonoma State University The University concurs with the recommendation. The University will review and enhance its procedures and internal controls to ensure the SEFA is complete and accurate. Estimated Completion Date: July 2026 Contact person: Sonoma State University David Crozier Associate Vice President, Financial Services (707) 664-3442 david.crozier@sonoma.edu
Compliance Requirement: Procurement, Suspension and Debarment Campus: Sacramento Recommendation: KPMG recommends the University implement controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension an...
Compliance Requirement: Procurement, Suspension and Debarment Campus: Sacramento Recommendation: KPMG recommends the University implement controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension and debarment check in the procurement file of each vendor. Corrective Action Plan: California State University, Sacramento The University concurs with the recommendations. The University will review and enhance its procedures and internal controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension and debarment check in the procurement file of each vendor. Estimated Completion Date: July 2026 Contact person: California State University, Sacramento Tabitha Leeds Senior Director of Accounting Services (916) 278-4679 leeds@csus.edu
COMPLIANCE REQUIREMENT: Disbursements to or on Behalf of Students Campus: Fullerton, Los Angeles Recommendation: KPMG recommends the University provide proper training on the disbursement notification requirements and apply its existing policies and procedures. Corrective Action Plan: California Sta...
COMPLIANCE REQUIREMENT: Disbursements to or on Behalf of Students Campus: Fullerton, Los Angeles Recommendation: KPMG recommends the University provide proper training on the disbursement notification requirements and apply its existing policies and procedures. Corrective Action Plan: California State University, Fullerton The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely disbursement notification. Estimated Completion Date: March 2026 Contact person: California State University, Fullerton Nick Valdivia Director of Financial Aid nvaldivia@fullerton.edu (657) 278-3064 Justin Chan Associate Director of Accounting Services & Financial Reporting juschan@fullerton.edu (657)278-8371 Corrective Action Plan: California State University, Los Angeles The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely disbursement notification. Estimated Completion Date: June 2026 Contact person: California State University, Los Angeles Linda Lopez Director, Financial Aid and Scholarships (323) 343-3247 llopez148@calstatela.edu
COMPLIANCE REQUIREMENT: Enrollment Reporting Campuses: Sacramento, Los Angeles Recommendation: KPMG recommends the University provide proper training on the enrollment reporting procedures and apply its existing policies and procedures. Corrective Action Plan: California State University, Sacramento...
COMPLIANCE REQUIREMENT: Enrollment Reporting Campuses: Sacramento, Los Angeles Recommendation: KPMG recommends the University provide proper training on the enrollment reporting procedures and apply its existing policies and procedures. Corrective Action Plan: California State University, Sacramento The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely and accurate reporting to NSLDS. Completion Date: December 2025 Contact person: California State University, Sacramento Tabitha Leeds Senior Director of Accounting Services (916) 278-4679 leeds@csus.edu Corrective Action Plan: California State University, Los Angeles The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely and accurate reporting to NSLDS. Estimated Completion Date: June 2026 Contact person: California State University, Los Angeles Linda Lopez Director, Financial Aid and Scholarships (323) 343-3247 llopez148@calstatela.edu
Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent) compares the meal counts in the claim to the SDS daily meal co...
Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent) compares the meal counts in the claim to the SDS daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: June 30, 2026. Name of contact person: Brett Elliott, Superintendent. Management response: The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.
Item: 2025-001 Assistance Listing Number: 64.024 Program: VA Homeless Providers Grant and Per Diem Program Federal Agency: U.S. Department of Veterans Affairs Pass-Through Agencies: n/a Contract/Pass-Through Grantor Identifying Number: CCAZ999-4582-649-TP-24 Award Year: October 2021 to September 202...
Item: 2025-001 Assistance Listing Number: 64.024 Program: VA Homeless Providers Grant and Per Diem Program Federal Agency: U.S. Department of Veterans Affairs Pass-Through Agencies: n/a Contract/Pass-Through Grantor Identifying Number: CCAZ999-4582-649-TP-24 Award Year: October 2021 to September 2023; October 2023 to September 2026 Compliance Requirement: Reporting Criteria: In accordance with the grant agreements, the Organization is required to submit per diem financial reports requesting payment based on the units of service provided multiplied by a per diem rate as specified in the grant agreement. Condition: In preparation of the per diem financial reports, the incorrect per diem rate was used to calculate the amount requested for payment for three reports. Phone Number: (602) 650-4852 Anticipated Completion Date: March 31, 2026 Views of Responsible Officials and Corrective Actions: The Organization has implement additional controls to ensure updates to the per diem rates are identified timely. The Organization will continue to ensure reports are reviewed and approved prior to submission to the granting agency. This review and approval will be clearly documented.
Item: 2025-002 Assistance Listing Number: 93.558 Program: Temporary Assistance for Needy Families Federal Agency: U.S. Department of Health and Human Services Pass-Through Agencies: Arizona Department of Economic Security Contract/Pass-Through Grantor Identifying Number: CTR062282 Award Year: July 2...
Item: 2025-002 Assistance Listing Number: 93.558 Program: Temporary Assistance for Needy Families Federal Agency: U.S. Department of Health and Human Services Pass-Through Agencies: Arizona Department of Economic Security Contract/Pass-Through Grantor Identifying Number: CTR062282 Award Year: July 2024 to June 2025 Compliance Requirement: Reporting Criteria: In accordance with the grant agreements, the Organization is required to submit monthly performance reports. Condition: Of the 22 reports tested, 11 were not submitted timely. Phone Number: (602) 650-4852 Anticipated Completion Date: March 31, 2026 Views of Responsible Officials and Corrective Actions: The Organization has implemented additional controls to ensure reports are submitted timely. The Organization will continue to ensure reports are reviewed and approved prior to submission to the granting agency.
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